Title I Directors Workshop Trisha Schock, Executive Director of - - PowerPoint PPT Presentation

Title I Directors Workshop

Trisha Schock, Executive Director of Admin Services

Title

• Fiscal requirements 2018 and beyond
• Braiding Funds
• SNS Methodology
• Lap & Title Allowable Expenses
• Time and Effort
• LAP HP Allocations
• Transferability & REAP
• Combining funds in SW Title I Program

Fiscal Requirement 2018 and beyond

• LAP HP Carryover – 10%
• Migrant Carryover – 100%
• Federal Outlook – reallocation to charter schools
• ESSA Pupil Spending per Building
• Monthly Grant management
• Increased compliance on grant award date expenditures

Monthly Grants Management

Monthly Grants Management

Monthly Grants Management

Braiding Funds – OSPI Presentation

• Requires district initiatives to be developed as teams
• Conduct needs assessment
• Allows multiple federal and state grants to support initiative

while maintaining award-specific identity

• Several allowable initiatives – provides examples
• Multi-Tiered System of Supports
• Grade-Level Literacy Rates
• Professional Learning
• Positive School Climate
• Regular Attendance
• 9th Graders on Track
• Dual Credit Programs

SNS Methodology

• Initial guidance intended to be more flexible to implement

comprehensive plans and demonstrate compliance

• Draft regulations proposed in 2016 were not adopted after

congress determined they were beyond the requirement.

• Dept. of Ed withdrew rulemaking guidance in July 2018
• January 2019 Dept. of Ed proposed new regulatory guidance, is
• pen for public comment

SNS Methodology

• Proposed Guidance
• No longer required to identify any individual cost or service supported

with Title I, Part A funds is supplemental.

• Must have a methodology to allocate State and local funds to schools

in each Title I school receiving State and local funds it would

• therwise receive if it were not receiving Title I funds.
• Must be “Title I Neutral”
• Other non-Federal funds not included in determining compliance

SNS Methodology Example

SNS Methodology Example

SNS Methodology

• FAQ
• Do not have to adjust allocation of State and local resources to account for

changes during the year that might result in non-compliance

• Compliance under new methodology required for 18-19 school year
• Not required to allocate Impact Aid or similar Federal Funds
• 3 instances schools are not required to meet SNS requirements
• If they are One School
• A grand span with a single school
• Only Title I schools
• If State and local funds are considered supplemental funds to Title I then

they are excluded from the SNS calculation

Example: State funds used in non-Title school for after-school tutoring, but Title I funds used in Title school for same program – not violation

Title I Allowable Expenses

• Common Misconceptions of Title I
• Funds may only be used to support reading / language arts and math

instruction

• May be used to support academic areas that the schools’ needs assessment

identifies as needing improvement

• Fund may only be used to provide remedial instruction
• May be used to upgrade the entire education program in the the school in order to

raise the achievement of the lowest-achieving students. This does not need to be achieved through remedial instruction. May be best achieved by preparing low- achieving students to take advanced courses

• Funds may only be used to serve low-achieving students
• May be used to upgrade the entire education program in a schoolwide program, in

which all students benefit and improve achievement of low-achieving students

Title I Allowable Expenses

• Common Misconceptions of Title I
• Funds may not be used to support preschool-aged children
• Schoolwide program may use funds to operate, in whole, or in part, a preschool

program to improve cognitive, health, and social-emotional outcomes for children from birth to age of free public elementary education. All preschool-aged children who reside in schools attendance area are eligible for attendance

• Allowable activities for Title:
• Provide eligible students with a well-rounded education
• Instructional Supports
• Non-instructional services that supports behavior, mentoring and social and

emotional learning that improves academic growth

• Improving school quality

LAP Allowable Expenses

• LAP offers supplemental services for K-12 students scoring below

grade level standard in English language arts and mathematics.

• Supports may include academic readiness, skill development, or

behavior supports to address barriers preventing students from accessing core instruction.

• Utilizing research-based best practices designed to increase student

achievement, students should see an increase in academic growth during the period of time supports are provided

• Must focus first on needs of K-4 students in reading or reading

readiness

• Must use data to develop programs that are most effective and

efficient

LAP Allowable Expenses

• Allowable Activities
• Extended Learning Time – before or after school, Saturdays or Summer
• Tutoring – including pull-out, push-in double-dosing support that occurs during the school

day

• Extending learning opportunities program for students in 8, 11, & 12
• Professional Learning – all educators working with LAP students explicitly tied to student

learning goals, student achievement, needs of diverse student populations, specific literacy and math content and instructional strategies, and suing student work to guide instruction

• Consultant Teachers – content and/or instructional coaches who work with teachers

serving LAP students

• Family Engagement – activities/support for families of LAP students – including family

engagement coordinators

• Community Partnerships – to increase student engagement and enhance students’

readiness to learn

Time & Effort - Single Cost Objective

Time & Effort reporting is important in ensuring that federal program funds are used to pay only their proportionate share of personnel costs.

• An employee whose salary is supported by only one federal program or

single cost object may be prepared on a semi-annual basis.

• Single Cost Objective: a single function, single grant or single activity. It

is possible to work on a single cost objective even if an employee works

• n more than one Federal award or on a Federal award and a non-

Federal award.

• They key to determining whether an employee is working on a single cost
• bjective is whether the employees salary & wages can be supported in

FULL from each of the federal awards on which the employee is working,

• r from the federal award alone if the employees salary is also paid with

non-Federal funds.

Time & Effort - Multi-Cost Objective

• An employee whose is supported by multi-cost objectives must

provide a monthly PAR or equivalent documentation supporting their time & effort.

• Instances of multiple activities or cost objectives for which a PAR

is required:

• More than one Federal award
• Federal award and non-Federal award.
• Unallowable activities
• Completed quarterly, signed for each month.
• Must be signed and dated by employee & supervisor

Duty Form / Schedule

PAR Form

PAR Form

Semi-Annual Cert

Time & Effort – Substitute Option

• Standard Requirements for substitute system
• Indicate the specific activity or cost objective that the employee worked on for

each segment of the employee’s schedule;

• Account for the total hours for which each employee is compensated during the

period reflected on the employee’s schedule; and

• Be certified at least semiannually and signed by the employee and a supervisory
• fficial having firsthand knowledge of the work performed by the employee.
• Revisions to an employee’s schedule that continues for a prolonged period of time

must be documented and certified.

• Any significant deviations from an employee’s established schedule that require the

employee to go back to a PAR form.

• Have to apply for substitute option with OSPI, not allowed until

approved.

Time & Effort – Substitute Option

• Can use the substitute option, employees must:
• Currently work on a schedule that includes multiple activities or cost
• bjectives that must be supported by monthly PAR’s
• Work on specific activities or cost objectives based on a pre-determined

schedule; and

• Not work on multiple activities or cost objectives at the exact same time on

their schedule.

• Under the substitute system, in lieu of PAR, eligible employees

may support a distribution of their salaries and wages through documentation of an established work schedule that meets the standards.

LAP HP Allocations

Transferability

• Transferability – can transfer all or a portion of the funding by

formula under certain Federal programs to their allocations under

• ther programs so they can address more effectively their unique

needs

• General Rules:
• May only transfer funds from Title II, Part A and Title IV, Part A
• No limits on percent of funds you can transfer
• Must consult private schools and local Tribal government as applicable
• Must notify OSPI 30 days prior with FP 821
• Once funds are transferred, they take on the identify of the Title to which

they were transferred and must be spent under the applicable rules

Transferability

Transferability

Transferability

• Transferability Accounting
• Retain transferred funds in their original account(s) but maintain documentation

that shows how transferred funds in the original account(s)

• Must maintain records demonstrating how a program’s total funds, including

transferred funds, were spent.

• It is not required to account separately for the expenditure of funds that were

transferred into a program and the allocation to which the transferred funds were added.

• However

, they must be charged/claimed to the program they funds were received from.

• Transferred funds should be treated as if they were an increase to the initial

allocations of this program. Spend transferred funds in accordance with requirements of the receiving program, including statutory set-asides.

• If there are required set-asides for the program to which you transferred funds,

the transferred funds need to be applied to the set-aside requirement.

REAP

• Transferability Accounting
• Retain transferred funds in their original account(s) but maintain documentation

that shows how transferred funds in the original account(s)

• Must maintain records demonstrating how a program’s total funds, including

transferred funds, were spent.

• It is not required to account separately for the expenditure of funds that were

transferred into a program and the allocation to which the transferred funds were added.

• However

, they must be charged/claimed to the program they funds were received from.

• Transferred funds should be treated as if they were an increase to the initial

allocations of this program. Spend transferred funds in accordance with requirements of the receiving program, including statutory set-asides.

• If there are required set-asides for the program to which you transferred funds,

the transferred funds need to be applied to the set-aside requirement.

REAP

• Alternative Fund Use Authority is a component of the Small Rurual

School Achievement Program

• Eligibility:
• Have a total average daily attendance of less than 600 students or serve only

schools that are located in counties that have a population density of fewer than 10 persons per square mile; and

• Serve only schools that have a NCES school locale code of 41, 42, or 43 or be

located in an area of the state defined as rural by a governmental agency of the state

• SRSA/REAP Eligibility
• Counties with a population density less than 100 persons per square mile or a

counties smaller than 225 miles as determined by OFM published each year

REAP

Combining Funds in SW Title I Program

• Schoolwide program has flexibility to consolidate funds from Title I,

Part A with other federal funds as well as state and local funds.

• Consolidating funds into a schoolwide program means that the

school treats the funds it consolidates as if they are a single “pool”

• f funds.
• Funds from contributing programs in the school lose their individual

identities and the school now has one flexible pool of funds.

• Still have to meet SNS compliance requirements
• Must maintain records that demonstrate that it meets the intent

and purposes of each federal program that was consolidated

• Eligible for schoolwide program if 40% or more students come from

low-income families

Combining Funds in SW Title I Program

• Must conduct a comprehensive needs assessment and develops a program based on

those needs

• Program Model Includes:
• All students and staff may participate in Title I funded activities
• Funds can support activity designed to improve schools educational program as long as it’s

consistent with the needs assessment

• Could upgrade curriculum for the entire school
• Extend school day or school year
• Establish a preschool program
• Improve school’s discipline program
• Hire additional teachers
• Reorganize classes to promote personalized learning
• Implement career academies
• Address climate or school culture issues

References

• Supplement Supplant Guidance
• https://www2.ed.gov/policy/elsec/leg/essa/snstitleiguidance.pdf
• Title I Fiscal Handbook
• http://www.k12.wa.us/titlei/pubdocs/TitleIPartA-ESSAFiscalHandbook2018-19.pdf
• Unlocking Federal Funds
• http://www.k12.wa.us/ESEA/pubdocs/UnlockingStateFederalProgramFunds.pdf
• Substitute System
• http://www.k12.wa.us/safs/TT/SustituteSystemFixedScheduleCertificationForm.pdf
• http://www.k12.wa.us/safs/TT/EDSubstituteSystemGuidelines.pdf
• Forms
• http://www.k12.wa.us/safs/TT/EDSampleEmployeeCertificationFixedSchedule.pdf
• Single Cost Objective
• http://www.k12.wa.us/safs/TT/EDSingleCostObjectiveGuidance.pdf
• LAP Allowable Activities
• http://www.k12.wa.us/LAP/pubdocs/LAPQuickGuide17-18.pdf